Last night, after everyone was gone for the weekend, Microsoft
announced that the European Commission had hit the company with a
statement of objections regarding its practice of bundling Internet
Explorer with Windows.
<http://www.microsoft.com/presspass/press/2009/jan09/01-16statement.mspx>.
A couple of hours ago, the Commission issued a confirming press
release. 
<http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/09/15&format=HTML&aged=0&language=EN&guiLanguage=en>.

I'd suggest taking some of the reports with a grain of salt. E.g., the
New York Times and the Washington Post have both just issued articles
claiming that the Commission ordered Microsoft to unbundle MSIE and
Windows throughout the E.U.
<http://www.nytimes.com/2009/01/17/technology/companies/17soft.html?_r=1&ref=technology>.
<http://www.washingtonpost.com/wp-dyn/content/article/2009/01/16/AR2009011604570.html?hpid=sec-tech>.
The problem is that neither attributed any source for that information
other than the two press releases, which do not state what remedy the
Commission's statement of objections specifies.

The original complaint was filed by Opera in January of 2008,
alleging, according to the Commission, that Microsoft had:

"... engaged in illegal tying of its Internet Explorer product to its
dominant Windows operating system. The complaint alleges that there is
ongoing competitive harm from Microsoft's practices, in particular in
view of new proprietary technologies that Microsoft has allegedly
introduced in its browser that would reduce compatibility with open
internet standards, and therefore hinder competition. In addition,
allegations of tying of other separate software products by Microsoft,
including desktop search and Windows Live have been brought to the
Commission's attention. The Commission's investigation will therefore
focus on allegations that a range of products have been unlawfully
tied to sales of Microsoft's dominant operating system."

<http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/08/19&format=HTML&aged=0&language=EN&guiLanguage=en>.

Opera had originally requested that the Commission *either* order the
unbundling of MSIE from Windows or to require the company to bundle
competing browsers with Windows. The press releases are silent as to
what remedy the Commission is ordering, so one has to wonder whether
the Post and the Times have read more into the press releases than
they state.

The cursory press releases do not discuss the proprietary extensions
and undermining of open web standards issues, nor the issues involving
the tying of desktop search and Windows Live to Windows. A further
complaint by the European Committee for Interoperable Systems ("ECIS")
--- largely an IBM front organization --- reported in the last linked
press release involves allegations that Microsoft undermined open
standards through, inter alia, withholding the specs for the MS Office
binary file formats, pushing OOXML to compete with the existing
OpenDocument international standard, and withholding the
communications protocols for its software stack that connect MS Office
to the company's new office productivity fortress under construction
on the server side, e.g., Sharepoint Server. That investigation later
expanded to encompass allegations that Microsoft had packed national
standardization bodies to get OOXML approved by ISO/IEC.

The ECIS investigation is still under way. It is conceivable to me
that the Opera complaint regarding the undermining of open web
standards has been rolled into that investigation rather than being
handled in the investigation whose preliminary result was just
announced. There is overlapping subject matter. I should also mention
that in European Comission parlance, an "investigation" has a sense
not commonly associated with investigations by U.S. government
agencies; an "investigation" is more equivalent to a U.S. Federal
Trade Commission administrative prosecution of antitrust charges,
whose final decisions can be reviewed by a federal court of appeals.
In this instance, the "investigation" involved is an administrative
prosecution by the Director General  of the Commission's Competition
Directorate, herself a member of the Commission. The "statement of
objections" just issued represents the Commission's proposed final
position, with the burden now shifting to Microsoft to persuade the
Commission that it has erred in the statement of objections. In other
words, Microsoft has one last chance to assist the Commission's
lawyers in refining the quality of the final decision. :-) Microsoft
has eight weeks to respond and can request an oral hearing.

Microsoft is in a largely untenable position because of its previous
behavior. DG Competition ruled against Microsoft in 2004 in regard to
disclosure of the Windows < > Windows Server communications protocols
and the company's bundling of Windows Media Player. Microsoft was hit
with a whopping fine and ordered to go forth and sin no more "with
similar object or effect." The company's 1-way definition of
interoperability was rejected and it was also ordered to disclose the
communications protocols with a degree of specificity sufficient to
place competitors on an "equal footing" in regard to the quality of
2-way interoperability Microsoft achieved with its own software. In
regard to WMP, Microsoft was ordered to market a version of Windows in
Europe that did not include WMP, what I dubbed the "Windows Unmedia
Edition."

Microsoft responded with what I can most charitably describe as
arrogance. Microsoft appealed and requested that the Court of First
Instance stay the Commission's order pending appeal. That request was
denied. The Windows Unmedia Edition was duly trotted out but Microsoft
sold it at the same price as the version of XP that included WMP.
There were audible rumblings of discontent from DG Competition staff
over Microsoft taking advantage of a loophole left in the order.
Microsoft added fuel to the fire by stalling the required
communications protocol disclosures and charging rather outrageous
fees for them. This resulted in a further, larger fine for what would
be analogous in the U.S. to as contempt of court.

Meanwhile Microsoft continued down the path of extending its existing
monopolies into new areas via software bundling practices and
inadequate disclosure of the interop interfaces for its software. In
simpler terms, one might say that Microsoft's managers made the
mistake of flipping off DG Competition, betting the company's business
plan on a reversal or substantial weakening of the DG Competition 2004
order in the Court of First Instance.

Big mistake. Very big mistake. Humongously huge mistake. On September
17, 2007 all 13 judges of the Court of First Instance issued a joint
decision that was instantly recognized as a landmark in the law
governing software interoperability.
<http://curia.europa.eu/jurisp/cgi-bin/gettext.pl?where=&lang=en&num=79929082T19040201&doc=T&ouvert=T&seance=ARRET>.
Microsoft won only a trivial collateral issue. The DG Competition
Order was otherwise upheld.  I will always remember the shocked look
on the face of Brad Smith, Microsoft's chief in-house legal counsel,
in a press conference an hour after the decision was released. The man
was rocked to his very core.

The problem Microsoft faced was that it had built a solid track record
that the fines and remedial orders issued by DG Competition were
inadequate to coerce compliance. And DG Competition has the power even
to break up companies when other remedial orders are inadequate.

So the company since then has been very responsive to every twitch of
DG Competition staff's  eyebrows. Many of the disclosures sought
through the ECIS complaint have already been made, with DG Competition
expressing approval for Microsoft's words when it announced the
disclosures but with a  stern reminder that the Commission expects
more than the right words coming from the Microsoft press office and a
reminder that the new disclosures were irrelevant to the issue of
whether Microsoft had committed past violations. The survival of the
company in its present form is potentially at stake.

There are also some incentives at work in the E.U. that don't come
into play in the U.S. Microsoft is a U.S. company, not European albeit
that it operates through a subsidiary in the E.U. The E.U. has no
incentive to continue to export its regional wealth to Redmond,
Washington. And the Commission has found a huge E.U. government
money-maker in prosecuting Microsoft for antitrust violations. So
further Microsoft antitrust violations in the E.U. have somewhat of a
"make my day" quality for DG Competition staff. Their return on
invested staff time and resources is enormous.

Because Microsoft transformed itself into the goose that lays the
golden eggs for E.U. government, I do not expect DG Competition to
break up the company absent truly outrageous and recalcitrant
behavior. But I also do not expect DG Competition to issue orders as
ineffective in restoring competition as the Windows Media Player
aspects of the 2004 order.

All of which boils down to saying that it's too soon to tell from the
outside what Microsoft has been ordered to do.

Because the news was only disclosed Friday night after everyone had
gone home, I do not expect much in the way of clarification before
Monday. Even then, it's apt to come in dribs and drabs and largely by
inference from small details rather than all at once. E.g., the
statement of objections that led to the 2004 order was never leaked
and E.U. government differs substantially from U.S. government in
regard to transparency. But Microsoft knows what the order says as
does Opera. There may be details that leak.

I apologize for the length of this missive, but this could potentially
be another decision that makes the ground move beneath our feet. If
Microsoft has in fact been ordered to unbundle MSIE from Windows, that
plays havoc with Microsoft's current business plan for monopolizing
the enterprise collaboration market. And if the company has been
ordered to stop undermining open web standards with proprietary
specifications, the company's "embrace, extend, and extinguish"
strategy could be near its end.  So I think the topic deserving of a
lengthy post.

We live in an interesting Time.

Best regards,

Paul



-- 
Universal Interoperability Council
<http:www.universal-interop-council.org>
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